Public Privacy Notice

How Clearup Solutions uses your Personal Data

Introduction

Clearup Solutions respects your privacy and is committed to protecting your personal data. This privacy notice (notice) will inform you as to how we look after your personal data when you contact us or visit this website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This notice is provided in a layered format so you can click through to the specific areas set out below.

WHAT IS PERSONAL DATA?

THE PERSONAL DATA WE COLLECT ABOUT YOU

HOW WE COLLECT YOUR PERSONAL DATA

HOW WE USE YOUR PERSONAL DATA

MARKETING

DISCLOSURE OF PERSONAL DATA

TRANSFERS OUTSIDE THE EEA

KEEPING PERSONAL DATA SECURE

DATA RETENTION

YOUR RIGHTS

COOKIES

COMPLAINTS

UPDATING THIS NOTICE

Purpose of this notice

You can request a copy of the details Clearup Solutions holds by emailing Catherine Maylin, at catherine@clearupsolutions.co.uk. This notice is issued on behalf of the Clearup Solutions so when we mention "Clearup Solutions", "we", "us" or "our" in this notice, we are referring to the relevant company, Clearup Solutions who are responsible for processing your data.

This notice aims to give you information on how Clearup Solutions collects and processes your personal data when you contact or access us or through your use of this website, including any personal data you may provide when you sign up to any newsletters, take out our services, or any other communications you have with us for example when you call, email or contact us via social media.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This notice supplements the other notices and is not intended to override them.

Controller

This notice applies to the processing of personal data by Clearup Solutions.

We have appointed Adrien Smith as the person who has responsibility for advising us on our data protection obligations. If you have any questions about this notice, including any requests to exercise your legal rights, you can contact us using the following details:

Clearup Solutions ltd

SVS House, Oliver Grove, London SE25 6EJ

adrien@clearupsolutions.co.uk

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave this website, we encourage you to read the privacy notice of every website you visit.

WHAT IS PERSONAL DATA?

Personal data is any information that tells us something about you. This could include information such as name, contact details, date of birth and passport details. It does not include data where the identity has been removed (anonymous data).

THE PERSONAL DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you when you make contact with us through this website, social media, applying for a vacancy, or any other means of contacting us. We have grouped together the different types of personal data as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and photographs.

Contact Data includes email address and telephone numbers.

Financial Data includes bank account details.

Transaction Data includes details about payments to and from you.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Wireless Data - includes for example device names, MAC addresses (i.e. unique device identifiers) and the date and time that the user connects to Clearup Solutions wireless networks. Information relating to the websites visited is not usually collected, unless the website is deemed to be malicious, or inappropriate by our security appliances used by Clearup Solutions.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this notice.

Special categories of personal data

Some information is classified as "special" personal data under data protection legislation. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

In very limited circumstances, we may collect special personal data about you. We will however, only collect or disclosure this special personal data where it is necessary to protect your vital interests (for example, if you are unwell at our premises, we may need to pass your personal data to medical professionals in order to seek assistance).

We do not collect any information about criminal convictions and offences.

If you include any special personal data when you contact us on the telephone, by email, through this website or any other means of communication, it is your responsibility to make sure you are happy for us to use that personal data in accordance with this notice. You should be aware that this personal data is more sensitive and is more heavily protected by data protection legislation, so you should avoid including this kind of data if possible.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

3 HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

Direct interactions - You may give us your Identity, Contact, Financial and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

become a client of Clearup Solutions ;

make contact with us through email, telephone, post or through social media regarding a query, feedback or complaint;

visit this website;

subscribe to any of our e-newsletters or request marketing to be sent to you.

Automated technologies or interactions - As you interact with this website, we may automatically collect Usage Data about how you use this website and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources - We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from analytics providers such as Google based outside the EU;

Identity, Contact and Marketing and Communications Data from marketing platforms such as Mail Chimp based outside the EU;

Identity, Contact, Profile and Marketing and Communications Data from survey providers such as Survey Monkey based outside the EU;

Identity Contact and Profile Data from social media platforms such as Facebook, LinkedIn, Instagram, Vimeo and Twitter based outside the EU;

Identity, Contact, Profile, Financial and Transaction Data from share registration service providers such as Equiniti based outside of the EU;

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4 HOW WE USE YOUR PERSONAL DATA

Under data protection legislation we are only permitted to use your personal data if we have a legal basis for doing so as set out in the data protection legislation.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need information to perform a contract we are about to enter into or have entered into with you;

Where we need to comply with a legal or regulatory obligation; or

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending you marketing communications via email. You have the right to withdraw consent to marketing at any time by contacting us.

Please refer to the Section below regarding the purposes for which we will use your personal data to find out more about the types of legal basis that we will rely on to process your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us using the contact details above if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new client.

(a) Identity; and (b) Contact.

Performance of a contract with you.

To manage our relationship with you which will include:

(a)Responding to your queries; and

(b)Notifying you about changes to our terms and conditions or privacy notice.

Necessary for our legitimate interests (to develop and grow our business understanding of clients and to inform our marketing strategy).

To enable you to complete a survey.

(a)Identity;

(b)Contact;

(c)Profile;

(d)Usage; and

(e)Marketing and Communications.

Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business).

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity; (b) Contact; and (c) Technical.

(a)Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and

(b)Necessary to comply with a legal obligation.

To use data analytics to improve this website, services, marketing, client relationships and experiences.

(a) Technical; and (b) Usage.

Necessary for our legitimate interests (to define types of clients for our services, to keep this website updated and relevant, to develop our business and to inform our marketing strategy).

To make suggestions and recommendations to you about services that may be of interest to you.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details above.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5 MARKETING

Direct marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We will provide you with a clear choice to opt into receiving any of our newsletters or other marketing communications when you first make contact with us.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or take p our services and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We do not share your personal data with any company outside of Clearup Solutions for marketing purposes.

Opting out

You can ask us to stop sending you our newsletter, marketing messages or other marketing materials at any time by unsubscribing from the mailing list, using the link provided in the newsletter email, or by using the contact details above.

6 DISCLOSURES OF PERSONAL DATA

We sometimes need to share your data with third parties for the purposes as set out in the table in Section 4.

Where we share your personal data with third parties we ensure that we have appropriate measures in place to safeguard your personal data and to ensure that it is solely used for legitimate purposes in line with this notice. We will always make sure that those third parties protect your personal data in the same way that we do.

We need to share your personal data with third parties who provide services to us to enable them to provide their services such as IT, payment and system administration services. We may also need to share your personal data with our professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.

Our websites are managed by various developers. As part of the service provided by these developers, they will help to maintain the security and the performance of our websites by: (i) encrypting data in transit and protecting user connections; (ii) using third party scanning services to scan against known web attacks; (iii) investigating site errors; and (iv) providing secure hosting services.

We will not usually disclose your personal data other than as set out above. However, there may be circumstances where we need to share personal data other than as anticipated above. These include:

Where we are legally required to disclose the information, for example because a court orders us to do so;

Where the disclosure of the personal data is required for the purposes of the prevention and detection of crime. This includes sharing the personal data with tax authorities and law enforcement agencies;

Where we need to disclose the personal data for the purpose of or in connection with any investigation of an alleged crime, legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights; and

As stated above in Section 2 (Special categories of personal data), we may in very limited circumstances collect special personal data about you but we will only disclosure this special personal data where it is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to pass your personal data to medical professionals in order to seek assistance).

7 TRANSFERS OUTSIDE OF THE EEA

When personal data is transferred to countries outside of the UK and the European Economic Area (EEA) those countries may not offer an equivalent level of protection for personal data to the laws in the UK. We will not transfer your personal data outside the (EEA).

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or

Please contact us using the contact details above if you want further information on the specific mechanism used by us when transferring your personal data.

8 KEEPING PERSONAL DATA SECURE

We know that you provide your personal data in good faith and expect it to be looked after. We take the security of your personal data seriously and we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We have also taken steps internally in order to ensure that our systems adequately protect your personal data. This includes for example:

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy. You can request details of these retention periods by contacting Adrien Smith using the contact details above.

YOUR RIGHTS

You have rights in respect of your personal data and this Section explains a bit more about those rights that are applicable to what we do with your personal data and when you can exercise them. If you would like more information about any of your rights, please contact us using the contact details above.

You have a number of rights in relation to your personal data, these include the right to:

Be informed about how we use your personal data;

Obtain access to your personal data that we hold;

Request that your personal data is corrected if you believe it is incorrect, incomplete or inaccurate;

Request that we erase your personal data in the following circumstances:

If we are continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected;

If we are relying on consent as the legal basis for processing and you withdraw consent;

If we are relying on legitimate interest as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing;

If the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)

If it is necessary to delete the personal data to comply with a legal obligation,

Ask us to restrict our data processing activities where you consider that:

Personal data is inaccurate;

Our processing of your personal data is unlawful;

Where we no longer need the personal data but you require us to keep it to enable you to establish, exercise or defend a legal claim;

Where you have raised an objection to our use of your personal data,

Request a copy of certain personal data that you have provided to us in a commonly used electronic format. This right relates to personal data that you have provided to us that we need in order to perform our agreement with you and personal data where we are relying on consent to process your personal data;

Object to our processing of your personal data where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal data; or

Withdraw consent where we are relying on consent to process your personal data. You can withdraw consent to our processing the personal data at any time;

Not be subject to automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you would like to exercise any of your rights or find out more information, please contact us using the contact details above. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner's Office. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Officer so please contact us in the first instance using the contact details above.

You are important to us, and so is protecting your personal data. We have high standards when it comes to collecting and using personal data. For this reason, we take any complaints we receive from you about our use of your personal data very seriously and request that you bring any issues to our attention.

UPDATING THIS NOTICE

We keep our notice under regular review in order to ensure that it properly reflects our use of personal data. This notice was last updated on 24thMay 2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.